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  • To: <cctc-draft-advice-letter@xxxxxxxxx>
  • Subject: comments
  • From: "Anjali K. Hansen" <anjali@xxxxxxxxxxxxxxxxxx>
  • Date: Tue, 17 Apr 2012 19:40:36 -0400

The Council of Better Business Bureaus (CBBB) would like to comment on the 
ICANN Board request for definitions, measures, and targets for competition, 
consumer trust and consumer choice.  

CBBB concurs with the recommendations of the Consumer Trust Working Group for 
ALAC, ccNSO, and GNSO and would like to provide the context for its views in 
support of the Consumer Trust Working Group.   

As CBBB has stated prior to the opening of the new gTLD application period, 
there is far too little control over the rampant crime that takes place via the 
Internet in the form of pirating of intellectual property, identity theft, 
phishing scams and other types of brand infringement and consumer fraud.   CBBB 
and its constituents – small and medium business, nonprofits and consumers – 
are victimized by Internet crime on a daily basis.  

CBBB believes that tracking of these issues via the metrics and methods set 
forth by the Consumer Trust Working Group will be essential.  In particular, 
CBBB requests that the costs of trademark abuse be tracked by calculating the 
number of defensive registrations that will follow in the new gTLD registries, 
as well as calculating the number of blocking of trademarks that will occur 
during sunrise periods in the new gTLDs.   Such costs are adverse to the public 
interest and ultimately consumers.  To minimize such costs, CBBB strongly urges 
ICANN to put in place a central trademark clearinghouse for valid trademark 
holders to block registries and registrars from sales of such valid trademarks 
to registrants.  This will reduce the amount of profiteering that has taken 
place in the past when registrars are allowed to sell others’ trademarks, which 
does nothing to increase competition on the Internet.   ICANN has essentially 
allowed the blatant violation of others trademark rights for too long and if it 
continues to allow this, it should document the amount of such illegal activity.

In addition, ICANN should develop mechanisms with law enforcement and the GAC 
that will allow the prosecution and punishment of rampant cyber criminals that 
are increasingly brazen in their email spoofing, spamming, database 
infiltration, and malware downloads.  While CBBB recognizes the need for an 
unencumbered Internet space, free from excessive regulatory control, there does 
need to be significant international prosecution of e-commerce crime and fraud 
that is taking place on the Internet.

If there is to be consumer trust on the Internet, there needs to be meaningful 
consumer protection.


Anjali Karina Hansen

Associate General Counsel

Council of Better Business Bureaus

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